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State Letter #07-08

ORR Recommendations and Proposed Reporting Requirements and Guidelines for Economic Self-Sufficiency

Published: April 4, 2007
Types:
State Letter
Tags:
data, self suffiency

TO: STATE REFUGEE COORDINATORS
WILSON-FISH PROGRAMS
NATIONAL VOLUNTARY AGENCIES
OTHER INTERESTED PARTIES

FROM: Martha E. Newton
Director
Office of Refugee Resettlement

SUBJECT: ORR Recommendations and Proposed Reporting Requirements and Guidelines for Economic Self-Sufficiency

The purpose of this State Letter is to review ORR proposals and recommendations that came out of ORR’s Economic Self-Sufficiency Work Group, and to solicit feedback on these proposals so that ORR can formalize clarifications or revisions to current reporting requirements related to refugee economic self-sufficiency. These recommendations were initially presented at the ORR Annual Consultation held in January 2007.

Work Group Background and Goals

In 2006, ORR established an Economic Self-Sufficiency Work Group comprised of ORR staff, State coordinators, Wilson-Fish programs, local and national Voluntary Agencies, Mutual Assistance Associations, an employment Technical Assistance provider, and the Department of State.

The Work Group revisits the work of a 1994 Work Group on Economic Self-Sufficiency, which allowed ORR to develop specific performance measures that have served as basis for reporting outcomes for State-Administered and Wilson-Fish programs since 1996.

The Work Group was established so that ORR could:

  • Review goals and performance measures related to refugee economic self-sufficiency
  • Clarify performance measures and select new or revised measures
  • Where possible, recommend policy and programmatic solutions to establish greater consistency and accuracy in reporting across State-Administered, Wilson-Fish, and Voluntary Agency Matching Grant programs.
  • Strengthen overall ORR policies and operations related to refugee economic self-sufficiency

The Work Group was not designed to reach consensus on any of the issues before it; ORR intended that individual group members would provide ORR with information that would help inform our policies and procedures.

ORR instructed Work Group members to consider “economic self-sufficiency” to be defined as “earning a total family income at a level that enables a family unit to support itself without receipt of a cash assistance grant.” This definition is taken directly from the ORR regulations at 45 CFR 400.2. Though ORR recognizes that true refugee self-sufficiency depends on a number of factors other than family income (including language acquisition, cultural integration, etc), it was determined that these issues of broader integration were more appropriate for ORR’s Integration Work Group. Economic Self-Sufficiency Work Group members were instructed to focus mainly on the financial and employment-related aspects of integration and self-sufficiency as mandated to ORR in the Refugee Act of 1980.

The Work Group members include:

  • ORR Staff
    –  Pam Green-Smith, Ken Tota, Josh Trent, Ron Munia, Carl Rubenstein, Moushumi Beltangady, Laura Garcia, Sowsan Deifallah, Jim Perlmutter, and Tim Forbes
  • Representatives from
    –  Department of State (Bureau of Population, Refugees, and Migration (PRM)) (ex officio)
    –  State-Administered Programs (Maryland, New York, and Texas)
    –  Wilson-Fish Programs (Alaska and Massachusetts)
    –  Local and National Voluntary Agencies (U.S. Conference of Catholic Bishops, Church World Service, Ethiopian Community Development Council, Hebrew Immigrant Aid Society, International Rescue Committee, Lutheran Immigration and Refugee Service)
    –  Mutual Assistance Association (Ethiopian Community Development Council)
    –  Employment Program Technical Assistance Provider (RefugeeWorks)

Work Group Activities

Work Group members convened in October 2006 to discuss the definition of economic self-sufficiency as in Federal Regulations, review and discuss current performance measures and reporting guidelines, consider “ideal” performance indicators for measuring refugee economic self-sufficiency, talk about which performance measures should be established, and discuss reporting issues related to the selected measures.

Subsequent to the meeting, the group members engaged in continued discussion (via an interactive Wiki web space and a series of conference calls) on the selection of performance measures, as well as discussion of issues related to reporting on several of the measures, the definition of caseload, reporting timeframes, which job should be reported if one client enters multiple jobs within the reporting period, and how to address the self-sufficiency outcomes of TANF (non-Refugee Cash Assistance (RCA)) clients.

ORR Recommendations on Performance Measures

On the basis of suggestions from various members of the work group and our own independent analysis, ORR recommends a number of new and revised performance measures, as well as changes in reporting timeframes. Seven performance measures are proposed here as what we consider to be the best (and most feasibly measurable) indicators of economic self-sufficiency. 

Performance Measures # 1 – 5 are meant to be reported on by all State-Administered and Wilson-Fish programs for all (enrolled 5-year eligible) clients. Measure 1 is to be reported on for Matching Grant Program clients as well.

Measure 1: Refugees Entering Employment

  • Grantees report on the number of refugees entering into unsubsidized employment, either full- or part-time, during the reporting period.
  • This proposed measure is the same as the current measure related to entered employment, with the clarification that the measure refers to the number of refugees who enter employment at any time within the reporting period, regardless of how many jobs they enter during the reporting period.

Measure 2: Average Hourly Wage of Refugees Entering Full-time Employment

  • Grantees report on the average hourly wage of refugees entering full-time employment during a given reporting period.
  • For refugees entering multiple jobs during the reporting period, grantees report on only the job with highest wage at placement for each individual refugee.
  • As with Measure 1, this indicator is linked to the number of eligible refugees rather than the number of jobs held by those refugees.

Measure 3: Refugees Offered Health Benefits through Full-Time Employment

  • Grantees report on the number of refugees offered health benefits through any full-time job placement during the reporting period.
  • For refugees entering multiple jobs during the reporting period, grantees report on the number of refugees holding any full-time job offering a refugee health benefits.  The selected job need not be the same job reported for the hourly wage measure. In addition, there is no requirement that the refugee take advantage of the offered benefits.
  • As with Measures 1 and 2, this indicator is linked to the number of eligible refugees rather than the number of jobs held by those refugees.

Measure 4: Cash Assistance Terminations Due to Earnings from Employment

  • Grantees report on the number of refugees whose cash assistance is terminated due to earned income in an amount that exceeds the income standard for the case based on family size, thereby rendering the case ineligible for cash assistance. For those clients enrolled in TANF rather than ORR-funded cash assistance programs, the cash assistance termination determinations would be based on whether the earned income is in an amount “predicted to exceed” the State’s TANF payment income standard.
  • This proposed measure is the same as the current measure related to cash assistance terminations, with the clarification that the measure refers to the number of refugees whose cash assistance is terminated based on the program’s eligibility policies, regardless of how many jobs they enter during the reporting period.
  • While this measure is retained, ORR proposes dropping the current measure related to cash assistance reductions.

Measure 5: Refugees Employed at 90 Days

  • Grantees report on the number of refugees who are employed on the 90th day after their initial employment placement during the reporting period (whether in the initial job or a different job).
  • This proposed measure is the same as the current measure related to 90 day employment, with the clarification that the measure refers to the number of refugees who are employed 90 days after initial employment in any job, regardless of how many jobs they enter during the reporting period.

Performance Measures #6 – 7 are to be reported on by State-Administered and Wilson-Fish programs for clients receiving RCA, and by Matching Grant programs. Each of these measures is a three-part measure. These measures are conceived as “snapshot” or “point-in-time” measures and are meant to assess the performance of eligible refugees in the months after arrival. ORR is still considering how exactly point-in-time data will be determined.

Measure 6: Economic Self-Sufficiency at 120 days (Snapshot)

  • Three part measure:
    a)  Grantees report on the number of cases that are self-sufficient (earning a total family income that enables a family unit to support itself without receipt of a cash assistance grant) 120 days after date of eligibility.
    b)  Grantees report on the average hourly wage of refugees in current job.
    c)  Grantees report on the number of refugees offered health benefits through their current job.

Measure 7: Economic Self-Sufficiency at 180 or 240 days (Snapshot)

  • Three part measure:
    a)  Grantees report on the number of cases that are self-sufficient (earning a total family income that enables a family unit to support itself without receipt of a cash assistance grant) 180 or 240 days after date of eligibility.
    b)  Grantees report on the average hourly wage of refugees in current job.
    c)  Grantees report on the number of refugees offered health benefits through their current job.
  • Whether the measure will be reported at 180 or 240 days is still under discussion.

Measures 6 and 7 are new for State-Administered and Wilson-Fish programs.

Additional Proposals and Outstanding Issues

1)  Proposal: Definition of Caseload

  • ORR proposes defining employment services caseload (used in Measures 1-5) as “the total number of refugees receiving employment services during the reporting period, excluding only those individuals exempted from employment services according to the state's policies and procedures.”
  • ORR proposes defining the self-sufficiency caseload (Measures 6-7) as composed of “family units” as defined in the ORR Regulations at 45 CFR 400.2, “an individual adult, married individuals without children, or parents, or custodial relatives, with minor children who are not eligible for TANF, who live in the same household.” All cases that received ORR assistance during the reporting period are included in the measure.

2)  Proposal: Adjust reporting timeframes to achieve consistency across programs

  • ORR proposes the institution of trimester reporting on the Federal Fiscal Year for State-Administered, Wilson-Fish, and Matching Grant programs.
  • This would allow for more consistency in measurement across programs, and allow for better assessment of the refugee program as a whole. Also, trimester reporting syncs up with the current 8-month RCA eligibility time frame, and reflects the current reporting scheme for the Matching Grant program.

3)  Proposal: Reporting on refugee TANF recipients

  • ORR proposes that economic self-sufficiency data on Measures 6 and 7 (self-sufficiency snapshot) be collected and reported on for all recipients of ORR-funded cash assistance, including RCA, Wilson-Fish, or Matching Grant program assistance.
  • Data on TANF recipients’ receipt of cash assistance terminations (Measure 4) will continue to be collected for those individuals who access ORR-funded employment services.

4)  Outstanding issue: How to measure Economic Self-Sufficiency for Measures #6 – 7

  • Measures # 6 – 7 state that economic self-sufficiency should be defined as earning a total family income that enables a family unit to support itself without receipt of a cash assistance grant.[1] ORR is still trying to determine what standard this should be measured against. Several possible options are under consideration:
    -Family income is measured against a state’s maximum TANF income standards for the family size. If a family unit earns more than the maximum income, it will be considered self-sufficient. It is important to note that many States have very low maximum TANF income standards, often far less than the Federal Poverty Line and frequently a very poor indicator of a family’s ability to support itself.
    -Family income is measured against the income standards of the ORR program in which the family is enrolled (this is particularly relevant to the Wilson-Fish program). If a family unit earns more than the maximum income, it will be considered self-sufficient.
    -Family income is measured against the Federal Poverty Line. While this is higher than the maximum TANF eligibility income in most States, it is not adjusted by locality. Applying this standard to refugees regardless of location might not give a clear indication of each individual refugee’s self-sufficiency.
    -Family income is measured against some local standard (such as the Consumer Price Index, which is available by Metropolitan Statistical Area). This might give a clearer picture of whether a family is able to afford some basic “basket of goods” in its community.
    -Each grantee determines the standard for “supporting oneself without receipt of a cash assistance grant” based on an analysis of whether the case is earning enough to meet basic living needs as identified in a self-sufficiency budget or some agreed-upon set of expenses (perhaps detailed in the State Plan or other planning document and approved by ORR).
  • ORR feels that the chosen standard should be clearly defined and applied so as to ensure maximum clarity in the reporting and interpretation of grantee data.

5)  Outstanding issue: Harmonization with Department of State, Bureau of Population, Refugees, and Migration

  • The proposed measures and timelines do not apply to the Department of State’s Reception and Placement program. 
  • ORR and PRM will assess the possibility of aligning certain definitions and reporting timeframes.

6)  Outstanding Issue: Structure of Matching Grant Program

  • To be consistent with other ORR programs, the Matching Grant Program is considering moving to a Fiscal Year program rather than a Calendar Year program.
  • As discussed under Measure 7, economic self-sufficiency could be measured at 180 days (the length of MG program eligibility) or 240 days (the length of RCA eligibility) after eligibility. Work Group members suggested that ORR might consider the possibility of moving MG from a 6 month (180 days) to an 8 month (240 days) program in order to improve synchronization between ORR programs.
    Next Steps

ORR solicits feedback and comments on the proposals, recommendations, and outstanding issues listed above. Please provide your comments (in the same order and format as the State Letter) to Moushumi Beltangady (moushumi.beltangady@acf.hhs.gov) by April 25, 2007.

Following the receipt of feedback, ORR will consult with members of the Work Group to reach final decisions about measures, reporting timeframes, and other policy and programmatic issues. It is anticipated that another State Letter or policy document will be released this summer detailing ORR’s final decisions and procedures.

Please contact Pamela Green-Smith (pamela.greensmith@acf.hhs.gov) or Moushumi Beltangady (moushumi.beltangady@acf.hhs.gov, 202-260-2613) with any questions or concerns.

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[1] A cash assistance grant should only include the financial assistance provided to refugees whose earnings fall below the programs’ respective income eligibility standard. Other financial assistance provided to the refugee in the form of a bonus, incentive or disregard based on the refugees’ achievement of a successful employment outcome as indicated in the approved State Plan or Wilson-Fish Agency application should not be considered as cash assistance for the purposes of measuring cash assistance terminations (measure 4) and economic self –sufficiency (measure 6 and 7).